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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

15) ll-C-41 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:27 PM Sheet 15 of 343 
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A-34-52 

^

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Km. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

Mr. John Schweitzer 

Composites Institute 

1441 White Street 

Ann Arbor, Michigan 48104 

Dear John: 

AUG 1 2 1996 

OFFICE OF 

AIR QUAUTY PLANNING 

ANO STANDARDS 

.'ft 

KISHRi 

$&>'. EPA AIR DOCKET 

Thank you for giving us the opportunity to review your 

summary of the July 29, 1996 Pultrusion Industry Council and MACT 

for Composites meetings. Enclosed are our comments on these 

summaries. 

Sincerely, 

\AJL^ 

Madeleine Strum 

Environmental Engineer 

Coatings and Consumer Products Group 

2 Enclosures 
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s 

Comments on July 29 meeting on MACT for pultrusion 

1. Revise last sentence: "EPA suggested ..., without specific 

requirements for quantification leakage." (Delete remainder of 

sentence.) (We are thinking that a reasonable definition would 

address both exposed resin and leakage but not quantification of 

leakage. For example, we would include in the definition an 

exposed resin length of no more than 15 inches and describe a 

leakage collection system that would avoid use of large, open 

drip pans, and be more like the funnel-like system for collection 

used in the Reichold experiment versus a drip pan.) 

2. Revise: "EPA thought the clearances at the PIC experiments 

were all significantly smaller than 3/8 inch. The PIC agreed 

that the 3/8 inch was not needed for all rovings/mats/tubes, but 

rather, was a worst case that encompassed all situations and 

would simplify the requirement. The PIC agreed to provide a 

table that would contain different allowable clearances for 

different situations." 

3. Keep first sentence. Add second and third sentence as 

follows: "EPA requested that the allowed backflow for die 

injection be based on the die injection machine which was tested. 

EPA noted that there was very little backflow on the tested 

machine and estimated it was no more than five ounces per hour." 

Keep last sentence. 

4. Revise: "EPA reported that the Tecton pultrusion facility in 

Fargo, ND, employs an incinerator to control emissions from 

pultrusion and achieves an overall control efficiency of 

95 percent. The device was employed primarily for the pultrusion 

operation; therefore, 95 percent overall control may be the new 

source flSSr. (Note that a dre~ injection machine that performs 

similar to the one which was tested in the PIC pultrusion study, 

with regard to backflow, would meet this level of control.) EPA 

agreed to provide the PIC all nonconfidential business 

information (CBI) about this control system-.. EPA considers the 

non-CBI information available for Tecton suffi&ient to support a 

new source floor of 95 percent." 

5. Delete the last part of the last sentence (after the 

semicolon) and replace with: "EPA agreed that it was important to 

know how line speed affects the percent available styrene. For 

example, the PIC indicated that the 11 percent emission factor 

was associated with a two feet per minute line speed (which is 
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typical for some pultrusion processes.) If the same machine was 

running at four feet per minute, the emission factor would be 

half of the 11 percent." 
— — - P H 

From: John Scfjweiteer To: Madeleine Strum Date: 8/5/96 time: 23:55:32 Page Z of 2 "~^^^^~~ 

URA H 

August 6, 1996 

To: Madeleine Strum, EPA 

Tom Griffiths, Omega Pullrusions 

Larry Connors, Liberty Polyglas 

Jim Gaudiel, Owens Corning 

Walt McSherry, Omega Pultrusions 

Nelson Douglas, Reichhold * 

John Barker, MMK i 

Tr: John Schweit7er, SPI/CI 

I've prepared the following summary of our July 29 meeting on MACT for pultrusion. Please 

review this draft and provide comments or corrections by August 16. 

1. EPA suggested that the allowable leakage from saturation chambers of preform injectors should be 

based on measurements of leakage from the actual device used in the PIC study. EPA also 

questioned applying the reduction achieved by the preform injector in the study to other preij^fe 

injectors with other quantities of exposed resin and leakage. John Barker agreed to provide a^ ^ 

quantitative description (surface area and amount) of the leakage (exposed to air) from the device 

used in the PIC study. EPA suggested that the Control Factor for preform injection be set at the 

overall control status (PECS) required for existing sources, and then the standard would contain 

only a reasonable description of preform injection, without specific requirements for leakage or 

exposed resin; the PIC agreed to consider this suggestion. 

2. I he PIC agreed to provide additional information about why 3/8 inch dearance is needed for 

reinforcement entrance to Wet Area Endosures. 

3. EPA suggested that the 5 pounds per hour backflow allowed in the PIC proposed MACT for direct 

die injectors is too high and is not. related to actual measurements. The PICT agreed to review and 

consider an allowed backflow based on a small percentage of resin processed. 

4. EPA reported diat the Techton pultrusion fadlity in Fargo, ND, employs an indnerator to control 

emissions from pultrusion; emissions from no other operations are controlled by this device; 

therefore incineration may be the new source MACT floor. EPA agreed to provide to the PIC all 

available information about this control system and any collection devices used at the pultrusion 

machine, ^spcdally information on occupational exposures to styrene; the PIC will review this 

information and attempt to assess the applicability of this technology to other pultrusion operations. 

The PIC asserted diat EPA should not rely on "CBI" data in setting MACT floors, since this will limit 

industry's ability lo fully evaluate Uie control ledmology. 

5. The PIC provided additional information on Uie amount of styrene processed per hour in tiie PIC 

Phase II study; EPA agreed that this information was fully responsive-to the Agency's request The 

PIC noted that, since emissions as a percentage of production is highly related to production rate, 

data from the IMC studies cannot be used to set valid emission factors; bl'A agreed that the data 

should not be used to set emission factors. 

pJ4:10AA6.44IH444 

•* 
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Summary of July 29th meeting on MACT for Composites 

1. Revise: "EPA requested one or more future meetings with 

Rob Haberlein and CI to explore further aspects of add-on 

controls. CI agreed to arrange for Rob Haberlein to be at these 

meetings." 

2. No comments 

3.. Revise: "CFA agreed to collect additional information from 

those facilities in the database that claim use of resins with 

less than 35 percent styrene content (and other controls thought 

by industry to be unlikely). EPA agreed to update the database 

when CFA provides the new information." (NOTE: I suggest a 

deletion of the last sentence since there may be a discrepency in 

what was meant by the statement. EPA is considering the use of 

averaging of HAP contents of different resins which are used in 

the same process subcategory. For example, a facility which uses 

10 tons of a 40 percent HAP resin and 10 tons of a 30 percent HAP 

resin would be considered to have an average HAP content of 

35 percent HAP.) 

4. Revise: "EPA disagreed with the industry position that the 

incinerator at ARE is primarily for painting. EPA is using that 

facility as a new source MACT floor." 

5. Statement is accurate except that American Standard can be 

used in setting the MACT floor for existing sources if the 

standard is delayed by an amount of time such that American 

Standard has had its control operating for more than 18 months 

prior to proposal or for more than 3 0 months prior to 

promulgation (whichever is later). 

6. Revise: "EPA agreed that the results of the CFA emission 

studies may be used to help quantify emission reductions achieved 

by the pollution prevention measures included in the studies." 

7. Revise last sentence: change "EPA/ESD" to^-RPA." 

8. Revise first sentence: "EPA suggested that work practices 

involving spray-up techniques are too difficult to enforce and to 

ensure that they are continuously achieving emission reductions 

to use as an alternative means of compliance with other MACT 

requirements." (No change to second sentence.) 
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9. Revise first sentence: "EPA disagreed with industry's claim 

that SBREFA should take precedence over CAA requirements, 

specifically, those criteria that pertain to setting MACT 

floors." (No change to second or third sentences.) 

10. No comments. 
From: Jotin Schweitzer To: Madeleine Strum Date: 8/6/96 Time: 23:40:04 P.8 

URA F I 

Augusts, 1996 epa0606.mem 

To: Madeleine Strum, EPA 

Bruce Jordan, EPA 

Steve McfMally, CFA 

Rob Haberlein, EECS 

Walt McSherry, Omega Pultrusions * 

Rosemarie Keiley, Keller and Heckman 

Tr: John Schweitzer, SPI/CI 

I've prepared the following summary of our July 29 meeting on MACT for composites. Mease 

review this draft and provide comments or csorrections by August 16. 

4. 

5. 

EPA agreed to meet with Rob Haberlein, and further evaluate industry's daim that the indneration 

of emissions from most composite manufacturing operations is a nct-negativc for the environment 

Cl agreed to arrange these meetings. 

EPA agreed thai fadlities with co-located operations (e.g.: SMC compounding and painting) are 

possibly not useful models in establishing MACT for one of the processes, if it can be shown that a 

control used by (lie fadlity is primarily for the oilier process. Open issues: what lo do wilh lhe 

fadlity (put it in its own subcategory?), and how to establish the primary purpose of a control. 

CFA agreed to collect additional information from those fadlities in the database that daim use of 

resins with less than 35% styrene content (and other controls thought by industry to be unlikely). 

TPA agreed to correct the database when CTA provides the new infonnation. TPA also agreed to 

consider data on HAP content in resin to be averages rather than maximums. 

EPA disagreed with the industry position that the indnerator at ARE is primarily for painting. 

EPA agreed that the control device at American Standard has been installed too recently for use in 

setting the MACT floor for existing sources, but not for new sources. 

EPA agreelTthat the results of the CFA emission studies will be used to help quantify the emission 

reductions achieved by the pollution prevention measures induded in the studies. 

Industry asked EPA to address the mis-use of information from the CFA and RTI emission studies as 

emission factors. EPA agreed thai lhe Agency staff responsible for AP-42 will review die available 

information, and make a determination of the best way to estimat^emissions from composite 

manufacturing; EPA/ESD will then issue appropriate guidance; this wilPBe°done in the near 

future. 
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Prom: John Schweitzer To: Madeleine Strom Date: 8/6796 Tim: 2*40:40 WJ« J 

DRAF I 

8. EPA suggested that work practices, spcdfically spray-up techniques, arc too difficult to enforce to 

play a large role in MACT. Industry agreed to prepare a 4MACT proposal that indudes work 

practices as MACT for spray-up, and submit to EPA for consideration. 

9. EPA disagreed with industry's daim that SBREFA compels EPA to consider small business impacts 

when selling MACT floors. EPA noted thai small business impacts are always important in 

regulation development EPA suggested that industry consider separate subcategories for small and 

large businesses. * 

10. Industry asked EPA to consider cost, energy, environmental, and small business impacts when 

setting MACT floors. TPA responded that the Art does not provide for 4MACT floors to be set in 

this manner; however, the Agency agreed to use whatever flexibility is provided in the Act to set 

reasonable MACT floors. ITA suggested that industry provide additional information about those 

fadlities that may be setting floors at unreasonable levels.